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To: scion who wrote (236)12/2/2005 1:07:10 PM
From: scion  Read Replies (1) | Respond to of 12518
 
TREATMENT OF IMPAIRED CLAIMS

The following class of creditors may be impaired due to the reduction in interest rates,
extension of the payment periods or reduction in payment periods.

Class 1 Class 12 Class 17 Class 20
Class 5B Class 16 Class 19

ARTICLE V

GENERAL PROVISIONS
5.1 Distributions to be made by the Debtor pursuant to this Plan Administrative and Class
16 Administrative to creditors shall be made by the Debtor’s Attorney.
5.2 The rights afforded in this Plan shall be in exchange for and in complete satisfaction,
discharge and release of all existing claims of any nature whatsoever against the Debtor or any of
its assets or property. Except by order of the Court or as otherwise provided herein, upon the
confirmation date, all existing claims against the Debtor that arose at any time before the entry of
the confirmation order including but not limited to all principal or interest shall be satisfied or
discharged and released in full, except as herein specifically provided. The Debtor's discharge shall
be effective as to each claim, regardless of whether a Proof of Claim was filed, whether the claim
is an allowed claim, or whether the holder votes to accept the Plan. All persons or entities shall be
precluded from asserting claims against the Debtor or its assets or properties or any other further
claims based upon any act or transaction or activity of any kind that occurred prior to the
confirmation date.
5.3 In the event an impaired class of creditors with a claim against the Debtor's estate is
determined to exist that class shall be entitled to vote separately to accept or reject the Plan. If sufficient acceptances are not received, the Debtor reserves the right to amend the Plan and/or to
proceed to "cram down" pursuant to the provisions of 11 U.S.C. § 1129(b).

...

IN RE: JAMES N. TUREK, CASE NO. 02-20411-PCY5 CHAPTER 11 Debtor.
...

Dated this 27th day of January, 2005.
/s/ C. Edwin Rude, Jr.
C. EDWIN RUDE, JR.
Florida Bar No. 0157985
322 McDaniel Street
Tallahassee, Florida 32303-6249
Telephone (850) 224-2422
Facsimile (850) 224-0762



To: scion who wrote (236)12/2/2005 3:46:11 PM
From: scion  Read Replies (1) | Respond to of 12518
 
With the exception of the Finance Network LLC d/b/a Export Finance Bank (hereinafter “Export Bank”), whose claim is based on litigation which is stayed as to Debtor and which is pending as to Wicklund...

Class 20: Unsecured Claims Of Debtor as Guarantor of Debts of
Wicklund and its Affiliates or as Co-Debtor/Defendant with Wicklund

This class consists of the claims of seven creditors holding claims in the amount of
$4,793,145.00. With the exception of the Finance Network LLC d/b/a Export Finance Bank
(hereinafter “Export Bank”), whose claim is based on litigation which is stayed as to Debtor and
which is pending as to Wicklund, these debts were created as a result of Debtor’s guaranty of
Wicklund obligations and Wicklund has agreed to the issuance of Wicklund Treasury Stock by
issuing shares numbering approximately two-thirds of the indebtedness owed each creditor (eg. a
$1,500,000.00 claim will receive 1,000,000 shares of Wicklund Stock). Upon confirmation of
Debtor’s Chapter 11 Plan of Reorganization, Wicklund, if not already issued, will issue stock to the
creditors in this class and upon the issuance of same Debtor will be released from any liability to said
creditors. Further, upon the sale of the Wicklund stock, any indebtedness of Wicklund to the
creditors in this class will be deemed satisfied and paid in full. The distribution of stock to members
of this class is in addition to any Wicklund stock previously given as security to a member of this class. A chart indicating said creditors and the amount of stock they are to receive is attached hereto
as Exhibit “C”.
...

IN RE: JAMES N. TUREK, CASE NO. 02-20411-PCY5 CHAPTER 11 Debtor.
...

Dated this 27th day of January, 2005.